The Italian Supreme Court has delivered a judgment stating that a fair market value price analysis must be applied to domestic intra-group transactions, despite section 111 of the Italian Tax Code providing that the country’s transfer pricing rules only apply to transactions between Italian and foreign related entities.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap